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Privacy Policy

DIVYDE Capital Partners is committed to protecting the privacy of our investors and other individuals from whom we may obtain personal data. This Privacy Statement describes how we collect, use, share and disclose personal data we collect on the websites owned and operated by DIVYDE (“Sites”) as well as through other means both online and offline.

This Privacy Statement applies to all natural persons who are not covered by either our Investor Privacy Notice or our Employee Privacy Notice. Users of our financial services should additionally refer to our Investor Privacy Notice, which is supplied to them in their subscription agreement and from time to time thereafter as required by law. Please note, we may use facilities outside of your home country to process, store or back up electronic information. If you have any questions about this Statement or whether it applies to you, please contact us at Information@DIVYDEPartners.com

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BY PROVIDING YOUR PERSONAL DATA TO DIVYDE OR OTHERWISE USING OUR SITE, YOU AGREE TO THE TERMS OF THIS STATEMENT AND OUR WEBSITE TERMS & CONDITIONS.

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Who We Are

When we use the term “DIVYDE" or "we," "us" or "our", we mean to refer collectively to the DIVYDE Capital Partners and its affiliates, including investment funds managed, advised or administered by it (an “DIVYDE Capital Fund”).

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The Sites may link to third party websites or services not owned or controlled by DIVYDE. Please note that this Privacy Statement does not apply to those third-party websites and DIVYDE is not responsible for the data collection practices of any third parties.

 

The Information We Collect and Use

When we use the term “Personal Data” we mean information that can be used to identify you as an individual person.

What Categories of Personal Data We Collect

We collect the following categories of Personal Data:

  • Identifiers: Identifiers such as your real name, alias, postal and residential address, email address, account name, Social Security number, driver’s license number, state identification card number, contact details, corporate contact information, tax identification number passport number, insurance Statement number and other similar identifiers.

  • Protected Classifications: Information classified as personal or protected information by state, federal or other applicable law, including your nationality, place and date of birth, race, color, national origin, age, sex, gender, marital status, number of children, citizenship status, information on criminal history/unlawful conduct and correspondence records.

  • Commercial Information: Commercial information, including tax information, credit history, bank account details, money transfers including communications on bank transfers, source of funds details, investor profile and details related to your investment activity, including financial products or investment services purchased, obtained, or considered, and other investing or consuming histories or tendencies.

  • Sensory Information: Voice mail, audio, visual (including your photograph and signature) and similar information.

  • Employment Information: Professional or employment-related information, including your employment, employer’s name, and income.

  • Education Information: Education information, including your level of education.

  • Inferences: Inferences that we draw from your personal data in connection with a determination as to your suitability to make an investment, your capacity to evaluate the merits and risks of investments and your qualification to make an investment according to the terms of such investment.

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How We Collect Your Personal Data

We collect Personal Data in various ways, including when you submit identifiable comments or other content to us on our Sites or when you otherwise contact us. We collect whatever information you supply and use this information to communicate with you if requested and to fulfill the purpose of the content submission. If you submit an application for employment with DIVYDE, we will collect information including your contact details, work history, employment needs and interests, and anything relevant to the job for which you are applying.

We may also obtain Personal Data on you from our portfolio companies, vendors (e.g., background check providers), advisors and other business partners, social media networks or other publicly accessible directories and sources. These may include websites; bankruptcy registers; tax authorities; governmental agencies and departments and regulatory authorities to whom we have regulatory obligations; credit reference agencies; sanctions screening databases; and fraud prevention and detection agencies and organizations, including law enforcement.·

Information Collected Automatically on Our Sites:

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We use various technologies to collect data on our Sites. As is true of most websites, we gather certain information automatically and store it in log files. This information may include IP addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp and/or clickstream data. For more information about our use of cookies and similar technologies, refer to our Cookies Policy, available here.

We and our service providers may also use cookies, scripts, and similar technologies to manage our websites, collect information about you and your use of our Sites. These technologies help us to recognize you and customize or personalize your experience.

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How to Manage Cookies

Most Internet browsers allow you to remove or manage cookie functions and adjust your privacy and security preferences. For information on how to do this, access the “help” menu on your Internet browser, or visit http://www.aboutcookies.org/how-to-control-cookies. Please note, however, that disabling our cookies may result in your inability to take full advantage of all of the features of our Sites.

To learn more about the use of Cookies by Google for analytics and to exercise choice regarding those Cookies, please visit the Google Analytics Opt-out Browser Add-on.

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Our website does not respond to Do Not Track Signals.

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How We Use Your Personal Data

We collect, store and use your Personal Data for business or commercial purposes including the following:

Processing that is necessary for compliance with applicable legal or regulatory obligations, including without limitation:

  • undertaking investor due diligence including anti-money laundering and counter-terrorist financing checks, including verifying the identity and addresses of our investors (and, where applicable, their beneficial owners);

  • sanctions screening and complying with applicable sanctions and embargo legislation;

  • complying with requests from regulatory, governmental, tax and law enforcement authorities;

  • surveillance and investigation activities;

  • carrying out audit checks, and instructing our auditors;

  • maintaining statutory registers; and

  • preventing and detecting fraud.

Pursuing our legitimate interests, or those of a third party to whom your Personal Data are disclosed, including without limitation:

  • managing, operating and growing our business and managing investor accounts, including through the use of third party service providers;

  • processing applications for employment;

  • complying with a legal, tax, accounting or regulatory obligation to which we or the third party are subject;

  • assessing and processing requests you make;

  • sending updates, information and notices or otherwise corresponding with you;

  • investigating any complaints, or pursuing or defending any claims, proceedings or disputes;

  • providing you with, and informing you about, investment products and services;

  • managing our risk and operations;

  • complying with audit requirements;

  • ensuring internal compliance with our policies and procedures;

  • protecting DIVYDE against fraud, breach of confidence or theft of proprietary materials;

  • seeking professional advice, including legal advice;

  • facilitating business asset transactions involving DIVYDE or related entities;

  • monitoring communications to/from us (where permitted by law);

  • creating, improving and developing our Sites and other products and services; and

  • protecting the security and integrity of our Sites and IT systems.

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We will only process your Personal Data in pursuance of our legitimate interests where we have considered that the processing is necessary, proportionate and, on balance, our legitimate interests are not overridden by your legitimate interests, rights or freedoms. Should we wish to use your Personal Data for any purpose that requires your consent, we will contact you to request it.

Sharing Your Personal Data

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We do not sell any Personal Data to unaffiliated third-parties and have not sold any Personal Data in the past twelve (12) months.

We may share your personal information with other entities within DIVYDE et including with DIVYDE Capital Funds for any of the purposes set forth above. We may share your Personal Data with our agents and service providers. In certain circumstances we may be legally obliged to share your Personal Data with relevant regulatory authorities, administrative agencies, law enforcement agencies, ombudsmen or other oversight bodies such as the U.S. Securities and Exchange Commission. They, in turn, may exchange this information with other applicable regulatory authorities, including foreign authorities and tax authorities.

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Our agents and service providers may process your Personal Data on our behalf, including with our banks, accountants, auditors and lawyers, which may be data controllers in their own right. Our service providers are generally processors acting on our instructions. Additionally, a service provider may use your Personal Data where this is necessary for compliance with a legal obligation to which it is subject (for example, to comply with applicable anti-money laundering and counter terrorist financing laws).

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We may share your Personal Data with prospective creditors of DIVYDE or future or present portfolio company of an DIVYDE Capital Fund, with portfolio companies directly, or with a third party that acquires, or is interested in acquiring, all or a substantial part of our assets or equity interests, or that succeeds us in carrying on all or a part of our business. In certain circumstances, we may share your Personal Data in connection with the investigation and assertion of legal rights.

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Sending Your Personal Data Internationally

The Personal Data that we collect from you may be transferred to, and stored at, a destination outside your home country including the United States. Such third-countries may not be deemed to provide the same level of protection for personal information as your home country. When we do so and to the extent required by applicable data protection laws, we rely on appropriate or suitable safeguards, including:

  • European Commission approved Standard Contractual Clauses—you may request a copy by contacting us as set forth in the Contact Information section below;

  • obtaining your consent to transfer Personal Data after first informing you about the possible risks of such a transfer;

  • when the transfer is necessary for the performance of a contract between you and DIVYDE, or if the transfer is necessary for the performance of a contract between DIVYDE and a third party, and the contract was entered into in your interest; and

  • when the transfer is necessary to establish, exercise or defend legal claims.

 

Retention of Your Personal Data

We will keep your Personal Data for as long as is consistent with the purposes for which we are processing it. For example, we may require it for our legitimate business purposes, to perform our contractual obligations, or where law or regulation obliges us to. We will retain some Personal Data after your relationship with us ends.

Protecting Your Personal Data

We apply technical, physical, and administrative information security measures designed to protect against unauthorized or unlawful processing of Personal Data, and against accidental loss or destruction of, or damage to, Personal Data, although we cannot guarantee that these will always be effective.

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Children’s Privacy

Our services are not intended for children under the age of 18. We do not knowingly collect information from children under the age of 18, and we do not target children under the age of 18.

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Data Subject Rights

Individuals in Australia, California, Canada, Cayman Islands, Europe, Hong Kong, Israel, Japan, Singapore, South Korea, Switzerland, the United Kingdom, and certain other jurisdictions may have certain data subject rights. These rights vary, but may include a right to:

  • be informed about the purposes for which your Personal Data are processed;

  • access your Personal Data, including requesting us to disclose to you the Personal Data we have collected, used and disclosed about you during the past 12 months;

  • stop direct marketing;

  • restrict the processing of your Personal Data;

  • have incomplete or inaccurate Personal Data corrected;

  • ask us to stop processing your Personal Data;

  • complain to a data protection authority;

  • obtain a copy of your Personal Data in a portable format;

  • opt out of the sale of Personal Data; and

  • require us to delete your Personal Data in some limited circumstances

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Depending on your jurisdiction, you may also be entitled to direct any complaints in relation to our processing of Personal Data to your national or local data protection supervisory authority. Please consult local authorities.

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The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard. Individuals who submit requests for access or erasure of Personal Data and certain other rights will be required to verify their identity by answering questions. For requests related to particularly sensitive information, we may require additional proof of identification. We will not disclose or delete any information until such individual’s identity is verified. If you are making a request for access, we may not be able to provide specific pieces of Personal Data if the disclosure creates a substantial, articulable, and unreasonable risk to the security of your Personal Data or our systems or networks. If you are making a request for erasure, we will ask that you confirm that you would like us to delete your Personal Data again before your request is submitted. We will process your request within the time provided by applicable law.

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You may designate an authorized agent to submit a request on your behalf by providing that agent with your signed permission to do so. If an agent makes a request on your behalf, we may still ask that you verify your identity directly with us and directly confirm with us that you provided the authorized agent permission to submit the request before we can honor the request. Agents who make requests on behalf of individuals will be required to verify the request by submitting signed authorization from the individual. We will not honor any requests from agents until authorization is verified.

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Managing Your Communication Preferences

We want to communicate with you only if you want to hear from us. If you wish to opt out of receiving any communications, you may do so at any time by contacting us using our contact information below.

 

Changes to this Statement

This Privacy Statement is subject to occasional revision, and if we make any material changes in the way we use your Personal Data, we will notify you by posting the revised notice on the Sites and updating the effective date above.

 

How to Contact Us

If you have any questions or comments about this Privacy Statement or other privacy-related matters, you may contact us in the following ways:

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